Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
In a case concerning alleged undisclosed foreign assets under the Black Money Act, the ITAT ruled in favor of the assessee. The Tribunal found that the AO had relied solely on uncertified documents received from a foreign government under DTAA without verifying their authenticity. The assessee had categorically denied any connection with the foreign bank accounts during sworn testimony. The ITAT emphasized that under the Banker's Book Evidence Act 1891, bank records must be properly certified to be admissible as evidence. Without authenticated copies or corroborating evidence, the revenue failed to establish the assessee's beneficial ownership of foreign assets. Consequently, the appellate order was set aside.
In a case concerning alleged undisclosed foreign assets under the Black Money Act, the ITAT ruled in favor of the assessee. The Tribunal found that the AO had relied solely on uncertified documents received from a foreign government under DTAA without verifying their authenticity. The assessee had categorically denied any connection with the foreign bank accounts during sworn testimony. The ITAT emphasized that under the Banker's Book Evidence Act 1891, bank records must be properly certified to be admissible as evidence. Without authenticated copies or corroborating evidence, the revenue failed to establish the assessee's beneficial ownership of foreign assets. Consequently, the appellate order was set aside.
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